Preventing counterfeit parts under AS 9100

Counterfeit-part prevention is an AS 9100 requirement. ITVC Global explains the requirement and practical controls that organisations can use when implementing the standard.

What is a counterfeit part under AS 9100?

3.1 Counterfeit part — original excerpt

An unauthorized copy, imitation, substitute, or modified part (e.g., material, part, component), which is knowingly misrepresented as a specified genuine part of an original or authorized manufacturer.

Note 1 to entry: Examples of a counterfeit part can include, but are not limited to, the false identification of marking or labelling, grade, serial number, date code, documentation, or performance characteristics.

Understanding the definition

An unauthorised copy, imitation, substitute or modified part, material or component that is deliberately misrepresented as a genuine part from the original or authorised manufacturer.

Examples include false identification of markings, labels, grades, serial numbers, date codes, documentation or performance characteristics.

AS 9100 requirements for counterfeit-part prevention

Because counterfeit parts can compromise product conformity in aviation, space and defence applications, the 2016 revision introduced specific prevention requirements.

8.1.4 Prevention of counterfeit parts

Plan, implement and control processes appropriate to the organisation and its products to prevent counterfeit or suspect counterfeit parts from being used or incorporated into products delivered to customers.

Note:

Prevention processes should consider:

• Training relevant personnel in counterfeit-part awareness and prevention.
• Monitoring component obsolescence and its effect on supply risks.
• Controls for procurement from original or authorised manufacturers, authorised distributors or other approved sources.
• Traceability of parts and components to their original or authorised manufacturers.
• Verification and testing methods for detecting counterfeit parts.
• Monitoring counterfeit-part reports from external sources, and segregating and reporting suspect or confirmed counterfeit parts.

Supporting records, including mill test certificates and certificates of conformity, must also be checked because falsified documentation can conceal the true identity or origin of a part.

Practical steps for implementation

1. Establish a counterfeit-part prevention process

Create a process suited to the organisation and its products that prevents counterfeit parts from being used or delivered. Include training so that relevant employees can recognise warning signs and apply prevention controls.

2. Monitor component obsolescence

Track obsolescence, availability and related purchasing risks. Obsolete parts are not automatically counterfeit; establish controlled sourcing and verification arrangements when normal supply routes change.

3. Control supply sources

Procure from original or authorised manufacturers, authorised distributors or other approved sources, using controls appropriate to the product and purchasing risk.

4. Maintain traceability

Establish records and identification methods that allow the origin of parts and components to be traced and verified, including the original or authorised manufacturer.

5. Establish verification and testing methods

Use verification and testing methods appropriate to the product and counterfeit risk. Combine these with supplier and traceability controls to support confidence in authenticity.

6. Monitor and report counterfeit-part information

Monitor relevant external reports and communicate suspected counterfeit-part information through the applicable reporting process.

7. Segregate and report suspect parts

Promptly segregate and report suspect or confirmed counterfeit parts to prevent their use or re-entry into the supply chain. Retain items needed for investigation under controlled conditions.

Effective implementation of Clause 8.1.4 supports product quality and safety in aviation, space and defence. Appropriate prevention controls help maintain customer confidence and supply-chain integrity.

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